Based on NFA's examination of D2W and Prestige, it appears that D2W, Prestige and Hunter have misled customers regarding the value of their investments, continue to solicit potential customers with false and misleading performance information and have not provided D2W's customers with an NFA approved disclosure document. D2W, Prestige and Hunter have not been able to provide current books and records to NFA supporting the current value or location of their purported assets and client funds, and have also misled NFA throughout its investigation of the firms.

Effective immediately, the Member Responsibility Action (MRA) and Associate Responsibility Action (ARA) prohibits D2W, Prestige and Hunter from soliciting or accepting any funds from customers or investors, soliciting investments for any managed accounts, pools or other investment vehicles, or placing any trades. D2W, Prestige and Hunter are also prohibited from disbursing or transferring any funds of customers, investors or pools over which they exercise control, or participants in any such pools, without prior approval from NFA.

The MRA/ARA will remain in effect until such time that D2W, Prestige and Hunter demonstrate that they are in complete compliance with all NFA Requirements. D2W, Prestige and Hunter may request a prompt hearing before NFA's Hearing Committee.